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PRIVACY POLICY




PROTECTION OF YOUR PRIVACY

This Privacy Policy and Credit Reporting Policy applies to all of the activities
of the EnergyAustralia group of companies operating in Australia (including The
Embedded Networks Company Pty Ltd, trading as seene and the Echo Group)
(referred to as ‘us’/’our’/or ‘we’) and On by EnergyAustralia products and
services supplied by us.  It describes how we manage personal information and
how we handle credit-related personal information. Our Website Policy (set out
below) also describes how we deal with certain information collected through our
website.

This policy was last updated on 1 July 2021.


PRIVACY POLICY

We are committed to respecting your privacy and protecting your personal
information in accordance with the Australian Privacy Principles contained in
the Privacy Act 1988 (Cth). This Privacy Policy explains how we deal with your
personal information and how to contact us if you have queries about our
management of your personal information. By providing us with your personal
information (including your sensitive information), you consent to the
collection, use, disclosure and storage of that personal information as set out
in this Privacy Policy. This Privacy Policy does not cover personal information
collected or held by us about our employees.

We may revise this policy from time to time. When we revise this policy, we will
publish the revised version on our website.

What kinds of personal information do we collect?

‘Personal information’ is information or an opinion, in any form (whether true
or not), about an identified individual or an individual who is reasonably
identifiable.

The kinds of personal information we collect and hold about you will depend on
the circumstances of collection, including whether we collect the information
from you as a customer, supplier, stakeholder, job applicant or in some other
capacity.

For example, if you are a customer or a potential customer, we may collect your
name, address, telephone number, date of birth, other forms of identification
and information about your financial circumstances, credit worthiness, credit
history and the conduct of your account, information in forms you submit
(including on-line enquiry or complaint forms) and payment details (including
metering data).  We may also collect sensitive information about you (see Do we
hold sensitive information about you?). We may also collect information directly
from you and/or from other data providers about what, how and when you buy
products or services and your stated or likely preferences, such as whether you
are interested in certain products or promotions. 

If you are acquiring a telecommunications service from us, we may collect
information regarding when and where you use our telecommunications services and
the networks used to provide those services. We may also collect personal
information from third parties as required by or in accordance with any industry
code or industry standard registered under the Telecommunications Act 1997
(Cth). Our telecommunications network operators are also authorised to collect
information about the contents and substance of the communications they carry by
Division 3, Part 13 of the Telecommunications Act 1997 (Cth).

All telecommunications providers, including EnergyAustralia, have an obligation
to retain certain network data and customer information (called ‘metadata’) for
a period of at least two years for use by criminal law enforcement agencies.
Network data has always been collected by our network operators so that they can
run their networks properly, and it is now being retained for us for two years
to meet the government requirement. 
We also collect customer information and retain it for at least 2 years. Please
consult
https://www.ag.gov.au/dataretention for more information on what we are required
to retain and why. 

If you deal with us in some other capacity (for example, as a community
representative or other stakeholder), we may collect your name, contact details
and any other information you choose to provide to us.

If we’re unable to collect your personal information, we may not be able to
provide you with our products or services or do business with you or the
organisation with which you are connected.

If you provide us with personal information about another person (e.g. about
your authorised representatives or other people residing at your premises),
please make sure that you tell them about this Privacy Policy, and obtain their
consent before providing us with their personal or sensitive information. 

How do we collect your information?

We may collect personal information in a variety of ways, including from you
directly (including when you interact with us in writing, electronically, via
telephone or via social media websites), from your authorised representative or
someone living at your premises, when you visit our website or other online
services (including when you submit a quote, expression of interest or contact
form or, in the case of job-seekers, when you register a public profile on an
online job board), when you participate in our events or promotions, from third
party introducers such as energy comparators, sales partners and resellers, when
we supply products or services to you, from credit reporting bureaus, and from
public sources of information and marketing and similar lists which are legally
acquired by us. We may also collect information about you from third parties
with whom we have business relationships.

We may also obtain information from other energy or telecommunications retailers
(for example if you move to us from that retailer), our upstream
telecommunications service providers, your energy distributor or the energy
market operator relating to energy usage or previous energy usage at your
premises, as well as from suppliers of equipment which we install or connect to
the network for you, from our sales agents and resellers, and from our related
entities and commercial partners and other third parties, such as builders and
real estate agents, who advise us of the details of new energy users at a
particular premises. At all times the collection of this information is obtained
by lawful means in a manner that respects your privacy.

We may also collect information (including detailed energy data) about your use
of products and services (whether those products and services are supplied by us
or through our sales agents and resellers) through means such as smart meter
devices and other products and solutions.  These devices may allow us to
remotely collect and provide you with detailed data regarding energy usage and
usage times. This gives you and us the ability to monitor your usage and compare
usage with other premises, make forecasts, track trends and environmental
impacts, and identify product and service improvements. We may also give you the
ability from time to time to connect ‘smart’ or internet-enabled appliances to
provide you and us appliance-specific usage data. 

We may also collect personal information about you by accessing data from other
sources and then analysing that data together with the information we already
hold about you to learn more about your likely preferences and interests. 

When you visit our websites, social media pages or mobile applications or click
on our online advertisements on other websites or applications, we may collect
information about you using technology which is not apparent to you, for example
“cookies”. For more information about how we use “cookies”, please see our
EnergyAustralia Website Policy.

How do we use your information?

Your privacy is respected, and we do not sell, rent or trade your personal
information.

We collect, hold, use and disclose personal information for a variety of
purposes to effectively conduct our business, including to:

 * supply our customers with products and services, including energy use
   management tools, and to administer and manage the supply of products and
   services (including billing and collecting debts and selling debts to third
   parties)
 * provide our customers and prospective customers with information about us,
   products and services, products and services offered by our related entities,
   including how use of our products or services can be improved
 * understand and analyse our customers' energy needs, usage and consumption
 * to verify our customers’ and prospective customers’ identity and personal
   information and help ensure our customer records are current and accurate 
 * identify customers that might be suitable candidates for certain pilot and
   trial programs
 * provide our energy distributors and other service providers with information
   to allow them to coordinate energy management solutions, measure usage
   changes and identify further opportunities to improve energy management
   solutions
 * customise your user experience on our website and other online services
 * ensure safety at our sites
 * conduct research and development (including surveys) to improve our products
   and offerings
 * conduct appropriate checks for credit-worthiness and for fraud for customers
   who have credit with us
 * comply with our legal and regulatory obligations
 * manage our relationships with our suppliers and stakeholders
 * consider job applicants for current and future employment

We may also use new technologies to combine information we have about our
customers and users with data from other sources, such as other EnergyAustralia
Group members and third parties, in order to provide tailored services and
solutions to our customers and improve our products and services and customer
experience generally.

We may also use your information for other purposes required or authorised by or
under law (including purposes for which you have provided your consent).

We may also use and disclose de-identified customer usage data for a range of
purposes, including network planning and product and service development and
improvement.

To help us carry out these activities, from time to time we disclose personal
information to other persons including:

 *  our contractors, suppliers, agents, related entities and partners who assist
   us to provide products and services and to administer, manage and improve our
   business, including companies that provide products and services based on
   smart meter data and companies who manage the distribution of energy.
 * service providers who provide installation, maintenance, meter reading and
   other services related to metering, and other goods and services that we
   offer such as solar, energy storage and management solutions.
 * companies in the EnergyAustralia group of companies, including the Echo Group
   and CLP, our parent company located in Hong Kong.
 * credit providers and agencies
 * debt collectors and debt buyers
 * relevant loyalty and rewards program partners
 * consumer finance providers
 * corporate finance and banking providers
 * organisations with whom we have commercial arrangements government and
   regulatory authorities (as required or authorised by law)
 * our professional advisors (such as auditors and lawyers)
 * organisations that assist us to conduct research or analyse data, including
   undertaking customer segmentation for marketing purposes.

We will take reasonable steps to ensure that these third parties are bound by
privacy obligations in relation to your personal information. Some of our
contractors and suppliers to whom your personal information may be disclosed are
located overseas, including in India, New Zealand, China, Hong Kong, Singapore,
Malaysia, the Philippines, UK, the European Union, South Africa and the US.
These countries may change from time to time.

How do we store your information?

We may store your information in hardcopy and/or in electronic form on computer
servers that are located in Australia and in some instances overseas. We take
steps to protect the personal information we hold from misuse, interference and
loss, and from unauthorised access, modification or disclosure.  For example, we
have implemented technology controls and organisational processes to assist us
to protect your personal information, including having in place confidentiality
obligations for employees and contractors, as well as implementing document
storage security policies, systems and site access restrictions.

Our websites also have security systems in place, including the use of firewalls
and data encryption. We also take care to store your information in a manner
that reasonably protects it from misuse and loss and from unauthorised access,
modification or disclosure. 

However, no data transmission over the internet can be guaranteed to be 100 per
cent secure. While we strive to protect your personal information, it is not
possible to guarantee or warrant the security of information sent over the
internet. Once we receive your information, we endeavour to ensure its security
on our systems. If you are concerned about internet security, you can contact us
by telephone, email or post. However, we may send information within
EnergyAustralia and to third parties, including over the internet.

Do we provide you with information about products and services?

If you are a customer or a potential customer, we may use your personal
information across the EnergyAustralia Group to provide you with information on
products, services and offers (from us, our related companies or companies that
we have partnered with) that we believe may be relevant to you or that you would
be interested in, even after you cease acquiring products or services from us,
and you consent to us doing so for an indefinite period of time unless you
advise us otherwise.  If you are a residential customer of the Echo Group, we
may send you information about other goods, services and offers (such as
EnergyAustralia energy plans) if you opt in to receive such information.

You can opt out of receiving marketing at any time (see below).

You consent to us sending you the information by direct mail, email, telephone,
mobile apps and SMS/MMS, unless and until you tell us not to contact you in
these ways.

How can you opt out of receiving information about products and services?

You can opt out of receiving marketing communications in any of the following
ways:

 * SMS or email marketing - click on the unsubscribe link or follow the
   instructions in the message you receive from us
 * Call the relevant customer service team:
   * EnergyAustralia customers
     Phone: 133 466 (Monday - Friday, 8am - 6.30pm AEST)
      
   * seene customers
     Phone: 1300 609 387 (Monday - Friday, 9am - 5pm AEST)
      
   * On by EnergyAustralia Customers
     Phone: 1800 108 633 (Monday - Friday, 9am - 5pm AEST)
      
   * Echo Group Customers (including Cherry Energy Solutions, eko energy and
     littil LED Lights)
     Phone: 1300 740 784 (Monday - Friday, 9am - 5pm AEST)
      
 * You can also opt-out in writing:
   
   The Privacy Officer
   EnergyAustralia/seene/On by EnergyAustralia/Echo Group
   Locked Bag 14060
   Melbourne City Mail Centre 8001

Please make sure the opt-out information you provide us matches with the contact
details we have for you in our system. In some circumstances, we may need to
contact you to obtain additional information, to verify your identity or to
clarify your request.

How do we make sure the information we hold about you is current?

We take reasonable steps to ensure that the personal information we collect, use
and disclose is accurate, up to date, complete and relevant.  

If you are a job seeker and would like to update your job seeker profile or no
longer wish to appear in our list of active job seekers, you can email us at
careers@energyaustralia.com.au.

Do we hold sensitive information about you?

We will only collect sensitive information about you with your consent (unless
we are otherwise allowed or required by law to collect that information).
Sensitive information includes information about your health, your race or
ethnic origin and religious beliefs.

We may ask you, your authorised representative or someone living at your
premises (or you may otherwise wish) to provide us with sensitive information
about you from time to time.  This might include health information, such as
information about a person's physical, mental or psychological health or
disability or information required to determine your eligibility for specific
discounts, services or treatment (e.g. eligibility for our hardship program). 

Some energy industry laws require us to collect your health information in
certain circumstances.  For example, we need to keep a record of information you
provide us where you have particular energy requirements due to special medical
needs or where you wish to apply for a government concession available in
relation to special medical needs. If you or someone living at your premises
requires life support equipment, you should tell us (and provide confirmation
from a medical practitioner (‘medical confirmation’)) so that we may register
your premises as having life support equipment, in which case certain
restrictions on disconnecting your premises will apply. 

The consequences of not providing us with health information will depend on the
purpose for which it would have been collected.  For example, where the
information is required to obtain a government concession, we will not be able
to process your application for that concession, or where the information is
required to register that someone at your premises uses life support equipment,
we do not have to register your premises, and power to your premises may be
disconnected by your distributor (which may affect the operation of that
equipment). 

We may disclose your health information to your distributor or, in some
circumstances, field vendors for several purposes (see How do we use your
information?). If you require life support equipment at your premises but are
not named on the account with us, we are permitted to disclose the associated
medical confirmation to the customer named on the account when they are
authorised under energy industry laws to request it. 

Do we record your phone calls to us?

Yes, we record and monitor phone calls for training, service quality control and
compliance purposes.

How can you correct your information?

Please let us know if the personal information we have about you is inaccurate,
incomplete or out of date and we will take reasonable steps to correct it,
including any information relating to credit.

How can you get access to your information?

You may request details of the personal information, including information
related to credit, we hold about you and we will generally provide you with
access subject to some exceptions permitted by law. For example, if providing
this access may disclose information about another person, or may disclose
commercially sensitive information, we may need to refuse to grant you access.
 Details about how to contact us are at the end of this document.

Charges may apply to cover the cost of us accessing and providing you with this
information. If we cannot provide you access, we will provide a statement of our
reasons.  

Credit Reporting Policy 

This Credit Reporting Policy applies to EnergyAustralia Pty Ltd ABN 99 086 014
968 (EA) and EnergyAustralia Services Pty Ltd ABN 73 081 074 160 (EA Services).
 EA Services is a related body corporate of EA.  EA Services provides services
to EA, including performing, on behalf of EA, tasks that are reasonably
necessary in processing an application for credit made to EA or in managing
credit provided by EA.  Both EA and EA Services are referred to collectively and
individually as "we" and "our" and "us" in this section of the Privacy Policy.

When you enter into a contract with EA, EA Services will collect and hold your
name, address, date of birth and driver’s licence number. EA Services may
disclose this information to Credit Reporting Bureaus (CRBs), including Equifax
Australia, illion and/or Experian Australia if EA Services decides to do a
credit check or credit assessment on you from time to time. You may contact the
relevant CRB to obtain its policy on how it manages your credit-related personal
information using the contact details below: 

Equifax Australia Information Services and Solutions Pty Limited (formerly known
as Veda)

Phone: 138 332

Mail: Attention: Public Access Division

Equifax Australia

PO Box 964

North Sydney NSW 2059

Email: membership.queryau@equifax.com

Web: www.mycreditfile.com.au

illion (Australia) Pty Ltd (formerly known as Dun and Bradstreet (Australia)

Phone: 1300 734 806

Mail: Attention: Public Access Centre

illion Australia

PO Box 7405

St Kilda Rd VIC 3004

Email: PACAustral@illion.com.au

Web: www.checkyourcredit.com.au

Experian Australia Credit Services

Phone: 1300 783 684

Mail: PO Box 1969

North Syndey NSW 2059

Email: creditreport@au.experian.com

Web: www.experian.com.au/consumer-reports

The detailed credit reporting information received back from a CRB (including
credit scores) and any information derived from the credit check (collectively,
"credit eligibility information") will be accessible only by a dedicated "credit
team" employed by EA Services, and may be used by that team to manage your
credit.

If you believe on reasonable grounds that you have been or are likely to be a
victim of fraud, you can request CRB not to use or disclose credit reporting
information about you. In addition, you can request the CRB not to use your
credit reporting information for the purposes of pre-screening of direct
marketing by a credit provider.

The CRB may include information that EA Services provides to the CRB in reports
that the CRB provides to other credit providers to assist them to assess your
credit worthiness.

If EA Services does a credit check on you from time to time with a CRB, the CRB
will generate a credit score for you and make this available to EA Services. EA
Services will use this information from time to time to help us assess your
credit worthiness, including by updating our own credit score for you.

If you become our customer, your "credit eligibility information" as described
above will be stored in the secure location that is only accessible by the
dedicated "credit team" employed by EA Services. However, the identification
information we collected from you (that is, your name, address, date of birth
and driver’s licence number) will be held in our customer database.

Some of our contractors to whom the identification information in our customer
database may be disclosed are located overseas, including in India, New Zealand,
China, Hong Kong, Singapore, Malaysia, the Philippines, UK, the European Union,
South Africa and the US.

If you don't become our customer, your identification information will be held
in our quotes database until such time as it is destroyed.

If, after reasonable follow up, you do not pay any outstanding amounts owed by
you to us EA Services may supply the CRB with this information along with
relevant personal information. This may include:

 * identification information about you
 * the fact that you have applied for credit and we are a credit provider to you
 * advice about payments more than 60 days overdue which are ‘in collection’
   that we are permitted to report to the CRB
 *  that, in our opinion, you have committed a serious credit infringement
 * that credit provided to you has been paid or otherwise discharged

Notification to the CRB that any of your outstanding payments are no longer
overdue will only be made following payment of the outstanding amount including
any accrued interest.

You’re entitled to access and seek the correction of the credit-related personal
information that we hold. If you have a complaint about the handling of your
credit-related personal information you can contact our Privacy Officer.

What if you disagree with our decision?

Where we make a decision about you or affecting you, you may ask us to explain
the basis on which that decision was made, and you may ask to see the personal
information (if any) on which our decision is based (see How can you get access
to your information?). 

EnergyAustralia Website Policy

Cookies

Like many companies, the EnergyAustralia Group (‘we’) operate a range of online
services to provide information and services such as website, mobile apps, email
and social media profiles, which may use ‘cookie’ technology. ’Cookies’ are
small text files a website can use to recognise repeat users, store registration
data, facilitate the user's ongoing access to and use of the website, allow a
website to track usage behaviour and compile aggregate data that will allow
content improvements.  Data within cookies may also be provided to us by other
businesses you have engaged with as well as other third parties. We may use the
‘cookie’ data provided to us in conjunction with our own data to provide a
tailored user experience across our website and online services as well as
provide you with more relevant advertising.

Cookies are not programs that come onto your system and damage files. In some
cases, cookies may collect and store personal information about you and, if that
is the case, we will extend the same privacy protections to that information as
we do to other personal information we collect about you.

Generally, the information collected through cookies relates to a device used to
access online content, such as an IP address or location data about the device.
Cookies may also collect information about the behaviours of the user of the
device, such as the websites visited by the user and their activity on the
website.  If you have logged into your EnergyAustralia My Account while you are
online or interacting with certain content, this cookie information can be
combined with information that identifies you as the end user of the relevant
device.

You can disable cookies or be warned when cookies are being used by adjusting
your internet browser or mobile device settings. However, disabling cookies may
mean that you are not able to access parts of our website or to take advantage
of the improved user experience or certain functionality that cookies can help
provide.

Visiting our website

When you visit our websites or use other online services, in addition to any
personal information you submit (e.g. for a quote or in a contact form), a
record of your visit will be recorded.

This record may include the following types of information:

 *  your server address
 *  your top level domain name (e.g. .gov, .au)
 *  the date and time of the visit
 *  pages accessed and documents downloaded
 * the address of any website that linked you directly to our site 
 * when you log into My Account, other anonymised information in relation to
   your account.  

We may use this record and other de-identified and aggregated information not
specific to you that we collect from third parties to: 

 *  help develop and improve our products and services and communication to
   customers and prospective customers; 
 *  to provide you with a tailored and relevant experience when using our
   website or other online services; and
 *  to assess unusual activity on the EnergyAustralia website and other online
   services.

Third party collection

Third parties may use cookies and other technology to collect information about
your use of our online services (including your computer’s IP address). These
third parties may store this information in countries outside of Australia and
may transfer the information they collect to other entities where required to do
so by law, or where those other entities process the information on their
behalf.  Third parties who may collect data about your use of our online
services include Demdex, DoubleClick, Facebook, Google and others. You can find
more details in the privacy policies for those third party services. This
includes information on how to opt-out of certain conduct.

Where there are third party cookies, you can disable the third party cookies or
be warned when third party cookies are being used by adjusting your internet
browser settings.

Third party websites

Our website and online services may contain links to third party websites. We
are not responsible for the content and the privacy practices of third party
websites and do not endorse or authorise their content.

You should familiarise yourself with each website's privacy policy and make your
own decision about providing personal information when visiting those sites.  

What if you have a complaint?

Please contact the Privacy Officer using the details below if you have any
concerns or complaints about the way we have collected or handled your personal
information (including in relation to credit). We will investigate your
complaint and respond to you in writing within 30 days. For complaints
specifically related to credit, we will also provide you in writing, within 7
days, an acknowledgement that your complaint has been received, setting out how
it will be dealt with by us. If you are not satisfied with our response, you can
contact us to discuss your concerns or lodge a complaint with the Australian
Information Commissioner (www.oaic.gov.au).  

How to contact us

You can contact us using the details below to:

 * arrange access to, or the correction of, personal information about you
 * request a hardcopy of this Privacy Policy
 * enquire generally about privacy matters (including in relation to credit)
 * discuss any issues relating to our Privacy Policy (including in relation to
   credit)

Mail:
The Privacy Officer
EnergyAustralia/seene/On by EnergyAustralia/Echo Group
Locked Bag 14060
Melbourne City Mail Centre 8001

EnergyAustralia Customers
Email (enquiries): enq@energyaustralia.com.au
Email (complaints): resolutions@energyaustralia.com.au

Seene Customers
Phone: 1300 609 387 (Monday - Friday, 9am - 5pm AEST)
Email: hello@seene.com.au

On by EnergyAustralia Customers
Phone: 1800 108 633 (Monday - Friday, 9am - 5pm AEST)

Echo Group Customers
Phone: 1300 740 784 (Monday - Friday, 9am – 5pm AEST)
Email: 
Cherry Energy Solutions    hello@cherryenergysolutions.com.au
eko energy            hello@ekoenergy.co
littil LED Lights        customerservice@littil.com.au
 

CAN THE WAYS IN WHICH WE USE YOUR INFORMATION AND THE CONDITIONS OF USE BE
CHANGED?

Periodically we will update this Privacy Policy to reflect changes to privacy
legislation, technological changes, company policy and customer feedback. You
should refer to our website from time to time to view the current version of
this Privacy Policy.

Read of our Privacy Policy.


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